John Robert Lind Co. Atty. Complaint No.: 2132530-1 Court File No.

:
*2132530-1*
Page: 1 of 8


V. 8/07


STATE OF MINNESOTA

COUNTY OF RAMSEY

DISTRICT COURT

SECOND JUDICIAL DISTRICT

COURT FILE NO.: _____________
PROSECUTOR FILE NO.: 2132530


State of Minnesota,

Plaintiff,


v.
John Robert Lind
(DOB: 08/26/1980)
391 91st Ave. NE
Blaine, MN 55434,







GROSS MISDEMEANOR
CRIMINAL
Summons Warrant
Order of Detention

Amended
Certified Juvenile
EJJ
Defendant.

The Complainant, being duly sworn, makes complaint to the above-named Court and states that there is
probable cause to believe that the Defendant committed the following offense(s):

COUNT 1
On or about the 25th day of February, 2014 to the 25th day of August, 2014, in Ramsey County, Minnesota, the
defendant, JOHN ROBERT LIND, did unlawfully engage in nonconsensual sexual contact with another
person.

Said acts constituting the offense of Criminal Sexual Conduct in the Fifth Degree in violation of MN Statute:
609.3451.1(1); 609.3451.2
Maximum Sentence: 1 year or $3,000 fine, or both.

COUNT 2
On or about the 26th day of August, 2014, in Ramsey County, Minnesota, the defendant, JOHN ROBERT
LIND, did unlawfully attempt to engage in nonconsensual contact with another person.

Said acts constituting the offense of Attempted Criminal Sexual Conduct in the Fifth Degree in violation of
MN Statute: 609.3451.1(1); 609.3451.2; 609.17.1
Maximum Sentence: 6 months or $1,500 fine or both.
John Robert Lind Co. Atty. Complaint No.: 2132530-1 Court File No.:
*2132530-1*
Page: 2 of 8


V. 8/07

STATEMENT OF PROBABLE CAUSE

The Complainant states that the following facts establish probable cause:

On August 26, 2014, New Brighton police officers were sent to Beisswengers located at 1823 Old Highway 8
NW, New Brighton, Ramsey County on a disorderly employee. Officers spoke to PM who said she thought
another employee was leaving bodily fluids in her workspace.

PM explained that she returned to her work space that afternoon and discovered another employee, JOHN
ROBERT LIND (DOB: 8-26-1980), standing at her desk with his back turned to PM. Lind had both of his
hands in front of him near his genitals. It appeared to PM that Lind was doing something at her desk but she
could not determine what it was. When Lind suddenly noticed that PM was behind him, he looked at her with a
dear in headlights expression. Lind kept his hands in front of him, quickly entered another room, and
slammed the door behind him. Approximately 10 seconds later, Lind came out of the room and said, I had a
question for you, but I forgot it, and he left the area.

PM inspected her desk and noted a strong odor that resembled urine, but was somewhat different and strange.
PM had a coffee mug with coffee on top of her desk. PM smelled her coffee and noted the same odor coming
from her coffee. PM originally thought the smell was due to spoiled milk. PM said that she had an ongoing
issue with a foul taste in her coffee but she had not considered that it may have been tampered with until that
day.

PM noted that there was a large amount of clear liquid on top of her desk and dripping onto the floor. PM
believed the liquid was either urine or semen. PM had a hair scrunchy on top of her desk that had absorbed a
large amount of the liquid, and she collected the item and placed it inside a plastic bag.

PM said that she had ongoing issues with Lind for the past several months. PM regularly came across Lind at
work while he had the zipper of his pants down. PM was offended often enough by his conduct that she told
Lind she would report him if he approached her with his zipper down one more time. Officers collected the
coffee mug, coffee, and hair scrunchy from PMs desk as evidence.

On August 28, 2014, Lind agreed to meet at the New Brighton Public Safety Center to discuss the situation
involving PM. Lind was told that he was not under arrest, that he did not have to speak with police, and that he
could stop talking and leave anytime he wanted. Lind said that he likes PM and is attracted to her. Lind
admitted that he ejaculated on PMs desk and in her coffee on August 26, 2014. Lind denied that his actions
were out of revenge because PM had threatened to report his behavior. When asked about approaching PM
with his zipper down, Lind said she had told him to stop but he did not recall her saying she would report him.
Lind said that he legitimately forgot sometimes to pull up his zipper. Sometimes, however, he did it on purpose
to perhaps get attention.

When told that PM had said her coffee had tasted odd for a couple of months, Lind admitted that he had
ejaculated into her coffee twice within the last six months. He ultimately admitted to four separate incidents
where he ejaculated on PMs desk or other items. Lind also said he used PMs hair scrunchy to wipe up his
ejaculate.

When asked why he did this, Lind said he thought it was a way to get PM to notice him. He denied that it was a
sexual compulsion that he could not control. Lind said he knew it was wrong, and he did it anyway. Lind

John Robert Lind Co. Atty. Complaint No.: 2132530-1 Court File No.:
*2132530-1*
Page: 3 of 8


V. 8/07


denied having ever done this to other women. Lind indicated he was sorry for what he had done, and he said he
knew it was gross and wrong.

When told of Linds admissions, PM replied, I knew it. I have drank his semen. I just thought it was spoiled
cream. PM did not believe that Lind had only ejaculated on or near her desk four times. She said her coffee
tasted odd on numerous occasions. She has seen drippings in and under her desk on multiple occasions. She
used a black light designed to pick up proteins and found several stained areas on her desk and chair.

Minnesota Statute 609.341, subd. 11, (a)(v) defines sexual contact to include the intentional touching with
seminal fluid of sperm by the actor of the complainants body or the clothing covering the complainants body.
John Robert Lind Co. Atty. Complaint No.: 2132530-1 Court File No.:
*2132530-1*
Page: 4 of 8


V. 8/07



Complainant requests that Defendant, subject to bail or conditions of release, be:
(1) arrested or that other lawful steps be taken to obtain Defendants appearance in court; or
(2) detained, if already in custody, pending further proceedings; and that said Defendant otherwise be dealt
with according to law.

COMPLAINANTS NAME:

Edward Sypniewski III

COMPLAINANTS SIGNATURE:

____________________________________



Subscribed and sworn to before the undersigned this ______ day of _________, 20_____.


NAME/TITLE:


____________________________________
SIGNATURE:


____________________________________



Being authorized to prosecute the offenses charged, I approve this complaint.

Date: 09/03/2014


PROSECUTING ATTORNEYS SIGNATURE:

____________________________________
Derek Fitch
Assistant Ramsey County Attorney
345 Wabasha Street North, Suite 120
St. Paul, MN 55102
651-266-3222/mc
Attorney Registration #328339
John Robert Lind Co. Atty. Complaint No.: 2132530-1 Court File No.:
*2132530-1*
Page: 5 of 8


V. 8/07

FINDING OF PROBABLE CAUSE
From the above sworn facts, and any supporting affidavits or supplemental sworn testimony, I, the Issuing Officer, have determined
that probable cause exists to support, subject to bail or conditions of release where applicable, Defendants arrest or other lawful steps
be taken to obtain Defendants appearance in court, or Defendants detention, if already in custody, pending further proceedings.
Defendant is therefore charged with the above-stated offense.

SUMMONS
THEREFORE YOU, THE ABOVE-NAMED DEFENDANT, ARE HEREBY SUMMONED to appear on the 29th day of
September, 2014 at 1:20 PM before the above-named court at Ramsey County Law Enforcement Center, 425 Grove Street, St.
Paul, MN 55101 to answer this complaint.
IF YOU FAIL TO APPEAR in response to this SUMMONS, a WARRANT FOR YOUR ARREST shall be issued.

WARRANT
Execute in MN Only Execute Nationwide Execute in Border States
To the Sheriff of the above-named county; or other person authorized to execute this warrant: I hereby order, in the name of the State
of Minnesota, that the above-named Defendant be apprehended and arrested without delay and brought promptly before the above-
named court (if in session), and if not, before a Judge or Judicial Officer of such court without unnecessary delay, and in any event not
later than 36 hours after the arrest or as soon as such Judge or Judicial Officer is available to be dealt with according to law.

ORDER OF DETENTION
Since the above-named Defendant is already in custody, I hereby order, subject to bail or conditions of release, that the above-named
Defendant continue to be detained pending further proceedings.

Bail:
Conditions of Release:

This complaint, duly subscribed and sworn to, is issued by the undersigned Judicial Officer this ______ day of _____________,
20_____.

JUDICIAL OFFICER:
NAME:
TITLE:
SIGNATURE:

___________________________________

Sworn testimony has been given before the Judicial Officer by the following witnesses:
COUNTY OF RAMSEY
STATE OF MINNESOTA

Clerks Signature or File Stamp:
STATE OF MINNESOTA
Plaintiff,
RETURN OF SERVICE
I hereby Certify and Return that I have served a copy of this
COMPLAINT upon the Defendant herein named.

Signature of Authorized Service Agent:

_________________________________
vs.

JOHN ROBERT LIND
Defendant.

John Robert Lind Co. Atty. Complaint No.: 2132530-1 Court File No.:
*2132530-1*
Page: 6 of 8


V. 8/07

FINDINGS OF FACT

Probable cause found that defendant committed the offenses charged.

Ordered defendant's motion to dismiss denied.

Plea of not guilty to all counts entered.

Trial and hearing on all issues set.



Dated: ________________________

_______________________________________
JUDGE OF DISTRICT COURT
John Robert Lind Co. Atty. Complaint No.: 2132530-1 Court File No.:
*2132530-1*
Page: 7 of 8


V. 8/07

DEFENDANT DATA / CHARGE SHEET ATTACHMENT A


DEFENDANT NAME:

JOHN ROBERT LIND

DOB: 08/26/1980

Defendant alias name(s):



Alias DOB(s):



Defendant last known
address:

391 91st Ave. NE
Blaine, MN 55434


State ID:



Fingerprint ID:

FBI ID:

St. Paul PD ID:

Offender ID:


OTHER DEFENDANT / CASE IDENTIFIERS:
Fingerprinted? No Yes
Handgun permit? No Yes (Issuing Agency: )
Location of violation:
IF DRIVING OFFENSE:
Driver's License Number: Issuing State:
License Plate Number: Issuing State:
Accident Type:
check all that apply
No injury/no damage Property Damage
Personal Injury Fatality
Blood Alcohol Concentration (BAC):
John Robert Lind Co. Atty. Complaint No.: 2132530-1 Court File No.:
*2132530-1*
Page: 8 of 8


V. 8/07


GROSS MISDEMEANOR SUMMONS

CT
NO
OFFENSE
DATE
STATUTE
TYPE
STATUTE
NBR
STATUTE
DESCRIPTION
OFFENSE
LEVEL
MOC G
O
C

AGENCY
ORI
CN NBR
FUNCTION

1 02/25/2014
to
08/25/2014
Charge 609.3451.1(1) Criminal Sex Conduct-5th
Degree-NonConsensual
Sex Contact
Penalty 609.3451.2 Criminal Sex Cond-5th
Deg-Nonconsensual Sexual
Contact-Penalty
G LAA77 N New Brighton
Police Dept
ORI - MN0620600
CN - 14010751
Charging
2 08/26/2014 Charge 609.3451.1(1) Criminal Sex Conduct-5th
Degree-NonConsensual
Sex Contact
Penalty 609.3451.2 Criminal Sex Cond-5th
Deg-Nonconsensual Sexual
Contact/Lewd Exhibition-
Under 16 Present - Penalty
Definition 609.17.1 Anticipatory Crimes-
Attempts
G LAA77 A New Brighton
Police Dept
ORI - MN0620600
CN - 14010751
Charging